Last Updated: January 10, 2023
Your privacy is important to us at The Chronicle of Higher Education, Inc. and its affiliates (“The Chronicle,” “we,” “us,” or “our”), and we are committed to safeguarding, preserving, and respecting your privacy rights. If you are a California resident, you have certain rights with respect to the collection, use, transfer, and processing of your personal information, as defined by the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code § 1798.100 et seq.
What Information Do We Collect?
The below examples are illustrative examples from the CCPA and do not reflect the specific pieces of information we collect.
In the previous 12 months, we have collected the following categories of personal information:
|A. Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Yes|
|B. Personal Information||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some Personal Information included in this category may overlap with other categories.
|C. Protected Classification Characteristics Under California or Federal Law||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||Yes|
|D. Commercial Information||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|E. Biometric Information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or Other Similar Network Activity||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation Data||Physical location or movements.||Yes|
|H. Sensory Data||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or Employment-Related Information||Current or past job history or performance evaluations.||Yes|
|J. Non-Public Education Information||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||Yes|
|K. Inferences Drawn of the Consumer||Inferences drawn from Personal Information identified above to create a profile about a consumer reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes|
Categories of Personal Information are as defined in Cal. Civ. Code. § 1798.140(v) (effective Jan. 1, 2023).
Sources From Which Personal Information Is Collected
We collect your personal information directly from you, from your interaction with the Site, from publicly available sources, and from third parties which collect the personal information directly from you. For more, please see the “Information We Collect From Other Sources” section above.
Business or Commercial Purposes for Which Personal Information Is Collected
Your personal information is used for the following purposes:
- To present our Services and its contents in a suitable and effective manner for you and your device;
- To contact you to provide you with information or services that you request from us;
- To advertise opportunities, services, or special events that we think may be of interest to you;
- To provide customer support, troubleshoot issues, manage accounts, and respond to requests, questions, or comments;
- To carry out our obligations and enforce our rights arising from any contracts; and
- To notify you about any additions, upgrades, or changes in our services.
Third Parties With Whom Personal Information Is Disclosed or Sold
In the preceding 12 months, we have disclosed the following personal information about consumers for business purposes:
- We disclose personal information in categories A (identifiers), B (personal), (personal), C (protected class), D (commercial), F (internet), G (geolocation), J (educational), and K (inferences) with service providers.
- We allow certain companies to use personal information in categories F (internet), G (geolocation) and K (inferences) to enhance online experiences and customize advertising.
- We disclose personal information in category A (identifiers) with vendors and business partners so that they can provide services to you or market products, information, campaigns, or services to you.
The California Attorney General has taken the position that certain analytical tools constitute “sales” under the CCPA. In the preceding 12 months, we used analytical tools that appear to constitute a sale in the following manners:
- We have sold personal information in categories A (identifiers), B (personal), C (protected class), D (commercial), and G (geolocation) to third parties so that they can market products, information, campaigns, or services to you.
We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age.
- Right to Know About Personal Information Collected, Disclosed, Shared, or Sold
You have the right to request that we disclose the personal information we collect, use, and disclose about you to third parties. There are two types of Rights to Know requests that you can make:
- Right to Know (Abbreviated Request): If you make a Right to Know (Abbreviated Request), you will receive the following information about you:
- Categories of personal information collected, sold, or shared;
- Categories of sources from which personal information is collected;
- Categories of third parties to whom the information is sold, shared or disclosed;
- Business or commercial purpose for collecting, sharing, or selling personal information;
- Categories of personal information disclosed for a business purpose and categories of persons to whom it was disclosed for a business purpose.
- Right to Know (Specific Pieces of Information Request): If you make a Right to Know (Specific Pieces of Information Request), you will receive the following information about you:
- Specific pieces of personal information collected about you.
This information will be provided to you free of charge, unless we determine that your request is manifestly unfounded or excessive. You may request this information twice in a 12-month period.
There are certain exceptions to a consumer’s Right to Know. We will state in our response if an exception applies.
- Right of Deletion
You have the right to request that we and our service providers delete any personal information about your which we have collected from you upon receipt of a verifiable request. This right is subject to certain exceptions. We will state in our response if an exception applies.
- Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business subject to certain laws and regulations.
For more information, please visit our Do Not Sell My Personal Information page
- Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising the privacy rights conferred by California law. We will not discriminate against you because you exercised any of your privacy rights, including, but not limited to, by: denying goods or services to you; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level of quality of goods or services to you; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services. We will also not retaliate against any employee, applicant for employment, or independent contractor for exercising their rights under the CCPA.
- Submitting Requests
You can submit your request by emailing us at email@example.com, or by toll-free phone at 833-919-1197.
- Verifying Requests
When we receive a request through one of the means described above, it must verify that the person requesting information or deletion is the California consumer about whom the request relates in order to process the request. To verify a California consumer’s identity, we may request up to three pieces of personal information about you when you make a request to compare against our records. We may also request that you sign a declaration under the penalty of perjury from the consumer whose personal information is the subject of the request.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in your request to verify your identity and will delete any information you provide after processing the request. We reserve the right to take additional steps as necessary to verify the identity of California consumers where we have reason to believe a request is fraudulent.
- Authorized Agents
You may choose a person or a business registered with the California Secretary of State that you authorize to act on your behalf to submit your requests (“Authorized Agent”). If you choose to use an Authorized Agent, we require that you provide the Authorized Agent with written permission to allow them to submit your request and that you verify your identity directly with us. Failure to do so may result in The Chronicle denying your request.